国际税收管辖权协调问题研究

A Study on International Coordination in Tax Jurisdiction

本文介绍国际税收管辖权的三种形式以及国际上的有关处理方式,重点说明我国对此的认识和实践,提出在体现国际税收管辖权划分的政府间避免双重征税协定中,要以立足国情、维护国家权益为出发点,协调处理好缔约双方税收管辖权的关系。

This paper introduces three types of tax jurisdiction and some typical tax jurisdiction cases in several countries as well as related theories and practices in China. Using the current situation and the rights and interests of our country as the starting point, the paper points out that the relationship of both contracting parties should be well dealt with when an agreement for the avoidance of double taxation is agreed upon.